On behalf of the PVD (Prepaid Verband Deutschland) we suggest to extend the list of exemptions for payments which are excluded from the scope of the strong customer authentication explicitly for payments with anonymous payment instruments which are based on e-money. According the EU Directive 2015/849/EU (4th AML-Directive) Article 12 and 15 certain low-risk e-money based payment instruments can be issued with a simplified customer due diligence. These prepaid instruments could be rechargeable or non-rechargeable. If these instruments are issued legally without customer identification and verification it is technical impossible to fulfill the required strong customer authentication. The ECB already stressed this exemption in its Assessment Guide for Security of Internet Payments of February 2014 (page 6).
PVD is an association of about 20 companies which are involved in the German prepaid industry (e-money and other prepaid instruments) as issuer, distributor, payment scheme, processor or service provider. For more information about PVD, please visit our website (www.prepaidverband.de).